Program Plan. We also obtained selected FRA regional inspection plans to identify how inspection resources are allocated at the local level. Finally, we obtained data on petitions filed by railroads and others from May 2009 through June 2011 for waivers of compliance with hours of service requirements. These data included information on who filed petitions, when they were filed, and what their status was as of June 2011. We verified these data with FRA and confirmed the status of each petition with FRA officials.
To address our objectives, we also interviewed relevant individuals and organizations, including the following:
Federal officials, including those from the National Transportation
Safety Board, FRA headquarters, and FRA regions 3, 4, 5, and 6. We selected these regional offices because we were already doing other work in the regions and the offices are geographically dispersed across the country. These four regional offices accounted for 60 percent of the hours of service inspections conducted from fiscal year 2005 through fiscal year 2010, and their territories cover all or parts of 23 states. We discussed with FRA the methods and procedures used to assess the fatigue risk in the railroad industry, the potential
operational and administrative impacts of RSIA’s hours of service changes on the railroad industry, and the processes and procedures FRA uses to ensure compliance with hours of service requirements. We also discussed FRA’s actions to implement pilot projects related to hours of service and FRA’s handling of petitions for waivers of compliance with hours of service requirements and the status of these petitions.
Fatigue and sleep research experts. We interviewed officials from the
firms involved in developing the FAST and FAID models, the Institute of Behavioral Research and InterDynamics, Inc., respectively, as well as fatigue and sleep research experts. Our discussions with the model developers focused on how and why the models were developed, what assumptions were used in the modeling process, how we should use the models to assess fatigue risk in the railroad industry, and what limitations might be associated with the model results. After we acquired the models, officials from these companies also trained us in how to use the models and how to interpret their results. We also interviewed four experts in fatigue research. We spoke with these individuals about issues related to work and fatigue and factors relating to the potential for fatigue risk. We also solicited their views
about fatigue models in general and the two fatigue models we acquired to analyze covered employee work schedules.
Railroad and railroad trade association officials. We interviewed
officials from all 7 class I railroads, 6 class II railroads, and 6 class III railroads as well as officials from a holding company that was the parent company for 39 class III railroads and 1 class II railroad. We discussed such issues as the effects of the hours of service changes on railroads and the covered workforce and the federal role in hours of service. We also discussed hours of service issues with officials from the Association of American Railroads, which represents the interests of class I railroads and the National Railroad Passenger Corporation, and the American Short Line and Regional Railroad Association, which primarily represents the interests of class II and III railroads. We also spoke with officials from the American Public Transportation Association about work they were doing to develop hours of service requirements for commuter and intercity passenger railroads. We were particularly interested in their views on the relationship between railroad work schedules and the potential for fatigue.
Representatives of labor organizations. We interviewed
representatives from the Brotherhood of Locomotive Engineers and Trainmen, American Train Dispatchers Association, United
Transportation Union, Transportation Communications Union,
Brotherhood of Railroad Signalmen, National Conference of Firemen and Oilers, and the Transportation Trades Department of the AFL- CIO. These organizations represent various employees that would be covered by railroad hours of service requirements, including train and engine employees, signalmen, and dispatchers. According to these organizations, they represent over 100,000 employees covered by hours of service requirements. We solicited their views on the effects of RSIA’s hours of service changes on their members, the benefits of these changes, and the federal role in monitoring and enforcing hours of service changes. We also solicited their views on waivers and exemptions to hours of service requirements for which railroads have applied.
We conducted this performance audit from April 2010 to September 2011 in accordance with generally accepted government auditing standards. Those standards require that we plan and perform the audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives. We believe that the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objectives.
This appendix discusses (1) why concerns about fatigue in the modern workplace have increased, (2) the nature of biomathematical models that have emerged to better understand sleep-work schedules and fatigue, and (3) GAO’s use of biomathematical fatigue models for analyzing the effect on workers of RSIA’s hours of service changes.
Over the past several decades, technology has enabled, and the
globalization of society has increasingly come to expect, round-the-clock activities. Society has become “24/7.” Planning for sleep is difficult when work schedules are unpredictable, and work that takes place outside normal business hours often requires people to sleep when humans are normally awake. These characteristics of the modern work world have led to a growing concern about human fatigue and its consequences in the workplace. These issues are particularly important to the rail industry, since rail workers often work on short notice and rail operations often occur at night.
When a person does not get enough sleep, certain areas of the brain involved in cognition are affected, engendering fatigue and an associated state of diminished capacity. This diminished capacity can have a variety of ramifications that may be of concern. For example, when fatigued, humans have more difficulty maintaining attention, become less
communicative, and have reduced situational awareness. They are then at greater risk of committing errors in their work, which can ultimately lead to more accidents. Concern about these effects has led to the
development of tools for better understanding worker fatigue, predicting its extent, and mitigating its effects.1
1David Neri, "Preface: Fatigue and Performance Modelling Workshop, June 13–14, 2002,"
Aviation, Space, and Environmental Medicine, Vol. 75, No. 3, Section II (March 2004).